Managing Nuclear Worker Fatigue

The Nuclear Regulatory Commission (NRC) issued a policy statement on February 18, 1982, seeking to protect nuclear plant personnel against impairment by fatigue from working too many hours. The NRC backed up this policy statement by issuing Generic Letter 82-12, “Nuclear Power Plant Staff Working Hours,” on June 15, 1982. The Generic Letter outlined guidelines such as limiting individuals to 16-hour shifts and providing for a break of at least 8 hours between shifts. But policy statements and guidelines are not enforceable regulatory requirements.

UCS issued a report titled “Overtime and Staffing Problems in the Commercial Nuclear Power Industry” in March 1999 describing how the NRC’s regulations failed to adequately protect against human impairment caused by fatigue. Our report revealed that workers at one nuclear plant in the Midwest logged more than 50,000 overtime hours in one year.

Barry Quigley, then a worker at a nuclear plant in the Midwest, submitted a petition for rulemaking to the NRC on September 28, 1999. The NRC issued regulations in the 1980s intended to protect against human impairment caused by drugs and alcohol. Nuclear plant workers were subject to initial, random follow-up, and for-cause drug and alcohol testing. Quiqley’s petition sought to extend the fitness-for-duty requirements to include limits on working hours. The NRC revised its regulations on March 31, 2008, to require that owners implement fatigue management measures. The revised regulations permit individuals to exceed the working hour limits, but only under certain conditions. Owners are required to submit annual reports to the NRC on the number of working hour limit waivers granted.

The NRC’s Office of Nuclear Regulatory Research recently analyzed the first five years of the working hour limits regulation. The analysis reported that in 2000, the year when the NRC initiated the rulemaking process, more than 7,500 waivers of the working hour limits suggested by Generic Letter 82-12 were being issued at some plants while about one-third of the plants granted over 1,000 waivers annually. In 2010, the first year the revised regulations were in effect, a total of 3,800 waivers were granted for the entire fleet of operating reactors. By 2015, the number of waivers for all nuclear plants had dropped to 338. The Grand Gulf nuclear plant near Port Gibson, Mississippi topped the 2015 list with 69 waivers. But 54 (78%) of the waivers were associated with the force-on-force security exercise.

The analysis indicates that owners have learned how to manage worker shifts within the NRC’s revised regulations. Zero waivers are unattainable due to unforeseen events like workers calling in sick and tasks unexpectedly taking longer to complete. The analysis suggests that the revised regulations enable owners to handle such unforeseen needs without the associated controls and reporting being an undue burden.

The regulatory requirements adopted by the NRC to protect against sleepy nuclear plant workers should let people living near nuclear plants sleep a little better.

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